Cases2301783/2024

Claimant v Dapper Collection Limited (in CVL)

23 February 2025Before Employment Judge Fredericks-BowyerLondon Southremote video

Outcome

Partly successful

Individual claims

Redundancy Paysucceeded

The tribunal found that Mr Lake was an employee of the 1st respondent from incorporation until dismissal by reason of redundancy when the business closed. Despite being a director and shareholder, he worked full-time in the retail unit as General Manager under the operational control of Mr Lawrence, who managed all governance and financial matters. The tribunal concluded there was mutuality of obligation and Mr Lake submitted to oversight and control, making him entitled to redundancy pay from the Redundancy Payment Service.

Unlawful Deduction from Wagessucceeded

The tribunal found Mr Lake was entitled to any amounts outstanding from the 1st respondent as an employee. Where these cannot be paid by the insolvent 1st respondent, the Redundancy Payment Service must compensate to the extent claims are covered by the scheme.

Facts

Two directors and shareholders of an insolvent retail company claimed redundancy payments from the Redundancy Payment Service. Mr Lawrence had controlled the operational, financial and governance aspects of the company throughout its life. Mr Lake worked full-time as General Manager in the retail unit, providing strategic vision but leaving all operational management to Mr Lawrence. Both had written employment contracts and were paid partly by salary and partly by dividends. The Secretary of State argued both claimants were not employees but directors running the business.

Decision

The tribunal dismissed Mr Lawrence's claim, finding he lacked mutuality of obligation as he was the controlling mind with no oversight, able to reduce his hours without consequence. The tribunal found Mr Lake was an employee throughout, as despite being a director and majority shareholder from 2018, he worked under Mr Lawrence's operational control, was required to fulfil set hours, and would face management intervention if performance fell. His willingness to accept reduced pay in hard times did not negate his employee status. Remedy to be determined at a later hearing.

Practical note

Being a director and even majority shareholder does not automatically preclude employee status if the individual works under the operational control of another director who manages the company's governance and finances, demonstrating genuine mutuality of obligation and subordination.

Legal authorities cited

Uber BV v Aslam [2021] UKSC 5Rajah v Secretary of State EAT/125/95Secretary of State v Neufeld and Howe [2009] EWCA Civ 280O'Kelly v Trusthouse Forte plc [1983] IRLR 369 CAAutoclenz Ltd v Belcher [2011] UKSC 41Carmichael v National Power Plc [1999] IRLR 43 HL

Statutes

Employment Rights Act 1996 s.230(3)Employment Rights Act 1996 s.230(2)Employment Rights Act 1996 s.230(1)

Case details

Case number
2301783/2024
Decision date
23 February 2025
Hearing type
full merits
Hearing days
1
Classification
contested

Respondent

Sector
retail
Represented
No
Rep type
lay rep

Employment details

Role
General Manager (Mr Lake); Director/Secretary (Mr Lawrence)
Salary band
Under £15,000
Service
10 years

Claimant representation

Represented
No